A non-domiciled and non-resident individual who created an offshore trust has recently died. Will distributions to the UK resident and domiciled beneficiaries be treated as capital or income and will the defence in ITA 2007, s 739 be applicable? And should the trust now become UK resident itself?
Even for non-domiciliaries with quite straightforward financial affairs, the new remittance rules are monstrously complicated and opaque, warns SIMON MCKIE